Savvy Butler – Privacy Policy

Savvy Butler is owned and operated by Glabur Holdings Ltd; a company incorporated in Cyprus. This privacy policy outlines how we collect, use, store, and protect your personal data when you use our digital guidebook and related services for short-term rental experiences.

We are committed to safeguarding your privacy and ensuring compliance with the General Data Protection Regulation (EU 2016/679) ("GDPR") and all applicable data protection laws.

1. Who We Are

Savvy Butler is a digital guest platform that allows property owners, managers, and guests to communicate, access stay-related information, and receive concierge services (e.g., airport transfers). When using our services:

• Data Controller: Glabur Holdings Ltd (for account holders and guests who interact with Savvy Butler directly)
• Data Processor: When acting on behalf of a property owner using our services for guest communication

If you have any questions, you can contact us at:

📧 info@glabur.com

2. The Legal Bases We Rely On

We process your data under the following legal bases:

• Consent: For marketing communications or service usage tracking
• Contractual obligation: To deliver our services to you or fulfill agreements
• Legal obligation: To comply with applicable laws or respond to lawful requests
• Legitimate interest: To operate and improve our services in ways that do not override your rights

3. When Do We Collect Your Personal Data?

We may collect personal data when:

• You visit our websites or digital guidebooks
• You create an account with us
• You use features of the guidebook, such as ride requests or communication tools
• A host inputs your data to provide you with arrival or local area information
• You interact with us via email, support, WhatsApp, or social media
• You engage with our marketing or subscribe to updates

4. What Personal Data Do We Collect?

Depending on your interaction, we may collect:

• Account Information: Name, email address, phone number, billing information
• Guest Information: Name, email, phone, check-in/out details, property visited
• Usage Data: Device info, IP address, browser type, interaction logs
• Payment Info: Processed by third-party PCI-DSS-compliant providers; we do not store card details
• Marketing Preferences: Opt-in status and engagement history
• Driver and Partner Data (where applicable): Name, service area, payout info

5. How & Why We Use Your Data

6. Marketing Communications

We may send you emails, SMS, or WhatsApp messages about new features or services only if you've opted in or have an existing relationship with us.

You can unsubscribe anytime by:

• Emailing us at info@glabur.com

7. Data Sharing

We do not sell your personal data. We may share it with trusted third parties who support our services under strict data protection contracts:

• Hosting & Cloud Providers (e.g., Vercel, Supabase)
• Payment Processors
• Messaging Platforms (e.g., Twilio WhatsApp)
• Analytics Tools (aggregated, anonymized)

We may also share data with:

• Law enforcement or regulators (where legally required)
• Property owners (when acting as processors on their behalf)
• Successors in case of a merger or business sale (subject to data protection standards)

8. International Transfers

Your data may be processed outside the EU/EEA (e.g., by OpenAI or US-based services). Where this occurs, we implement appropriate safeguards such as:

• Standard Contractual Clauses (SCCs)
• Data processing agreements with sub-processors

9. How We Protect Your Data

• Secure encrypted hosting (HTTPS, TLS)
• Role-based access controls and authentication
• Encrypted password and API key storage
• Strict internal data access policies

10. How Long We Keep Your Data

11. Your Rights

Under the GDPR and local laws, you have the right to:

• Access your data
• Correct inaccurate data
• Request deletion of your data
• Restrict or object to processing
• Data portability (in structured formats)
• Withdraw consent at any time
• File a complaint with your data protection authority

To exercise your rights, contact us at info@glabur.com

12. Complaints & Regulation

If you are unhappy with how we've handled your data, you may contact the Office of the Commissioner for Personal Data Protection in Cyprus at http://www.dataprotection.gov.cy or your local data authority.

13. Updates to This Privacy Policy

We may update this notice from time to time to reflect changes to our services, technologies, or legal obligations. The most recent version will always be available at www.savvybutler.com/privacy (coming soon).